Sounds reasonable but why doesn't the Company just say to the Transfer Agent. Give requestors the information that they are requesting concerning the Shares. Ungagged TAs give you the information over the phone and why do they do this. They have nothing to hide and give the TA the ability to be fully transparent over the phone.
Get rid of the pony express and come up to the present. TAs have all of the information concerning each and every share in a Company. Many CEOs have no idea of what the present status of shares are as they run a business and not into looking for what became unrestricted or restricted as of this date.